This public comment responds to the U.S. Department of Labor proposed rules that introduce extensive changes to the regulations that govern the Registered Apprenticeship system. The proposed rules seek to rescind or revise the provisions in sections 29 CFR parts 29 and 30, which promote equal opportunity and affirmative action in apprenticeship including through explicit enforcement responsibilities and mechanisms, replacing the current requirements with the single standard of complying with federal and state nondiscrimination laws.

Why This Matters

The proposed rules seek to facilitate the expanding Registered Apprenticeship system and reducing its administrative burden. Yet, the existing regulations play an important role: they help “safeguard the welfare of apprentices” as statutorily required, ensure that—with the support of registration agencies—apprentices are positioned to succeed, and they foster an apprenticeship system that is more reflective of the full range of workers and communities across the United States.

What We Found

Evidence shows these goals can be achieved more effectively through other strategies that build on the strengths of the current rules:

• The estimated cost savings of the NPRM from reduced administrative burdens represent only 0.13 percent of total sponsor costs, and sponsors do not regularly report regulatory compliance as a major barrier to operating their programs.
• The proposed rule could safeguard the welfare of apprentices by retaining investigative, technical assistance, and enforcement capabilities for registration agencies, establishing a clear complaint process for apprentices, supporting early intervention, and preserving and strengthening administrative deregistration authority.
• Employers and practitioners request continued access to consistent, high-quality data to modernize the system, demonstrate its value and benefits, and support continued expansion. Eliminating standardized demographic fields would not lessen burden or cost—it would lessen impact.
• The Administration should consider pursuing evidence-based regulations that speed up and simplify the registration process, such as streamlined cross-state reciprocity or expedited review for programs using high-quality occupational frameworks or national program standards. These changes promote the expansion of apprenticeship and could be a more effective use of public apprenticeship resources.
• Evidence shows that outreach and nondiscrimination practices—such as affirmative action plans, universal outreach, and equal employment opportunity efforts to engage underutilized labor markets—support the growth of the apprenticeship system by reaching new communities, add value to employers by expanding their talent pipeline, and make apprenticeship more representative of the broader workforce. Reducing or removing these practices would have the opposite effect.
• The Department should also consider expanding the apprenticeship system while reducing its burden outside of rulemaking through cost-effective and evidence-based strategies including employer outreach and technical assistance, deploying technology to simplify the registration and apprenticeable occupation process, offering off-the-shelf national apprenticeship frameworks and standards, and increasing investment in both apprenticeship infrastructure and offsetting employer costs.

How We Did It

We analyzed the federal Registered Apprenticeship Partners Information Database System (RAPIDS) and reviewed existing evidence. We also drew on our Registered Apprenticeship experience spanning research, work in federal and state apprenticeship agencies and nonprofits, and technical assistance to programs and apprenticeship leaders at the national, state, and local levels.